Commercial and industrial loans "made to finance construction that are not secured by real estate" are reported in RC-C, Part I, Item 4.... which is one of the two line items included in the definition of small business loan for CRA purposes. While unsecured "land develpment" loans for commercial purposes aren't specifically detailed as an example, I didn't see it included in another category and would tend to think it is also reportable in RC-C, Part I, Item 4, and, threfore, a small business loan for CRA purposes (provided the dollar limit test is met).